INDEPENDENT ACCOUNTANTS' REPORT
To the Board of Directors of
American Gas Index Fund, Inc.:
We have examined management's assertion about
American Gas Index Fund, Inc.'s (the "Fund's")
compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 under the Investment Company Act of
1940 (the "Act") as of March 31, 2000, included in the
accompanying Management Statement Regarding
Compliance with Certain Provisions of the Investment
Company Act of 1940. Management is responsible for
the Fund's compliance with those requirements. Our
responsibility is to express an opinion on management's
assertion about the Fund's compliance based on our
examination.
Our examination was made in accordance with standards
established by the American Institute of Certified Public
Accountants and, accordingly, included examining, on a
test basis, evidence about the Fund's compliance with
those requirements and performing such other
procedures as we considered necessary in the
circumstances. Included among our procedures were the
following tests performed as of March 31, 2000, and
with respect to agreement of security purchases and
sales, for the period from October 13, 1999, the date of
our last examination, through March 31, 2000:
* Confirmation of all securities held by Rushmore
Trust and Savings, FSB ("Rushmore Trust") in book
entry form for the account of the Fund;
* Confirmation from Rushmore Trust that the
securities held for the account of the Fund were held
for the account of Rushmore Trust by Mellon Bank,
N.A. ("Mellon"), as agent for Rushmore Trust;
* Confirmation with Mellon of all securities held by
Mellon in book entry form for the account of
Rushmore Trust;
* Confirmation with brokers that all purchases and
sales outstanding were in agreement with the Fund's
records;
* Reconciliation of all such securities to the books and
records of the Rushmore Trust and the Fund;
* Confirmation of all repurchase agreements with
brokers and agreement of underlying collateral with
the broker's records; and
* Agreement of two security purchases and two
security sales since our last report from the books
and records of the Fund to broker confirmations.
We believe that our examination provides a reasonable
basis for our opinion. Our examination does not provide
a legal determination on the Fund's compliance with
specified requirements.
In our opinion, management's assertion that American
Gas Index Fund, Inc. was in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of
the Investment Company Act of 1940 as of March 31,
2000 with respect to securities reflected in the
investment account of the Fund is fairly stated, in all
material respects.
This report is intended solely for the information and use
of management and the Audit Committee of the Board
of Directors of American Gas Index Fund, Inc. and the
Securities and Exchange Commission and is not
intended to be and should not be used by anyone other
than these specified parties.
Deloitte & Touche LLP
Princeton, New Jersey
April 25, 2000
Management Statement Regarding
Compliance with
Certain Provisions of the Investment
Company Act of 1940
We, as members of management of American Gas
Index, Fund, Inc. (the Fund), are responsible for
complying with the requirements of subsections (b) and
(c) of Rule 17f-2, "Custody of Investments by
Registered Management Investment Companies," of the
Investment Company Act of 1940. We are also
responsible for establishing and maintaining effective
internal controls over compliance with those
requirements. We have performed an evaluation of the
Fund's compliance with the requirements of subsections
(b) and (c) of Rule 17f-2 as of March 31, 2000 and from
October 13, 1999 (last examination date) through March
31, 2000.
Based on this evaluation, we assert that the Fund was in
compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 of the Investment Company Act of
1940 as of March 31, 2000 and from October 13, 1999
(last examination date) through March 31, 2000, with
respect to securities reflected in the investment accounts
of American Gas Index Fund, Inc.
Richard J. Garvey
Chairman
Edward Karpowicz
Controller
